Schnell v. Department of Services for Children, Youth and their Families

Summary

The Supreme Court of Delaware affirmed the termination of the father's parental rights. It held that excusing reunification services under 13 Del. C. § 1103(d) was constitutional as applied because the State proved a prior involuntary termination by clear and convincing evidence and the statutory best-interests determination supplied sufficient procedural protection. The court also held that the Family Court properly found termination to be in the child's best interests based on the statutory factors.